FREEDOM OF INFORMATION ACT ANNUAL REPORT TO THE CONGRESS FOR THE YEAR 1984
Document Type:
Collection:
Document Number (FOIA) /ESDN (CREST):
CIA-RDP87M00539R001802870007-6
Release Decision:
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Original Classification:
K
Document Page Count:
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Document Creation Date:
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Document Release Date:
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Sequence Number:
7
Case Number:
Publication Date:
February 7, 1985
Content Type:
REPORT
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STAT
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74920 Federal Register / Vol. 45, No. 221 / Thursday, November 13, 1980 / Rules and Regulations
CENTRAL INTEU.IGENCE AGENCY
32 CFR Part 1900
Public Access to Documents and
Records and Declassification
Requests
AGENCY: Central Intelligence Agency.
ACTION: Final rule.
EFFECTIVE DATE: November 13. 1980.
? 1900.25 Fees for records services.
(a) Search and duplication fees shall be
charged according to the schedule set forth
in paragraph (c) of this section for services
rendered in responding to requests for
Agency records under this part. Records
shall be furnished without charge or at a
reduced rate whenever the Coordinator
determines that a waiver or reduction of
the charge is in the public interest because
furnishing the information can be consid-
ered as primarily benefiting the general
public. Thus, the Coordinator shall deter-
mine the existence and extent of any identi-
fiable benefit which would result from
furnishing the requested information and
he shall consider the following factors in
making this determination:
(1) The public or private character of the
information sought:
(2) The private interest of the requester.
(3) The numbers of the public to be
benefited:
(4) The significance of the benefit to the
public;
(5) The usefulness of the information to
the public; and
(6) The quantity of similar or duplicative
information already in the public domain
In no case will the assessment of fees be
utilized as an obstacle to the disclosure of
the requested information. The Coordina-
tor may also waive or reduce the charge
whenever he determines that the interest of
the government would be served thereby.
Fees shall not be charged where they would
amount, in the aggregate, for a request, or a
series of related requests, to less than $6.
Denials of requests for fee waivers may be
apptilled by writing to the Executive Secre-
tary of the Information Review Committee,
via the Coordinator.
(b) hi order to protect the requester and
the Agency from large. unexpected fees,
when it is anticipated that the charges will
amount to more than $25, the processing of
the request shall be suspended until the
requester indicates his willingness to pay.
The requester shall be notified and asked
for his commitment to pay all reasonable
search and duplication fees. At his option,
the requester may indicate in advance a
dollar limitation to the fees. In such all
event, the Coordinator shall initiate a
search of the system or systems of records
deemed most likely to produce relevant
records. instructing the system managers to
discontinue the search as soon as the stipu-
lated amount has been expended ?Vheri?
an advance limit has not keen stipulated.
the Coordinator may, at his discretion or at
the behest of the requester. compile an
estimate of the search fees likely to be
incurred in processing a request, or of such
portion thereof as can readily lye estimated.
The requester shall be promptly notified of
the amount and be asked to apprt we its
E.\ penditure. In those cases where I hr Coor-
dinator estimates that the fees will be sub-
stantial. an advance deposit of 50 percent
of the estimated fees will bc required. in
those cases xx here there is reasonable evi-
dence that the requester min possibb fad
to pay the fees which would be accrued by
processing his request. an adY wire deposit
of 100 percent of the estimated fees will lye
required. The notice or request for an
advance deposit shall extend an offer to the
requester xx herein he is afforded all oppor-
tunih to revise the request in a manner
calulated to reduce the fees. Dispatch of
such a mit ice or request shall suspend the
running of the period for respinse ln the
Agency until a repk is received from Ow
requester.
tc) The schedule of fees for services
performed in responding to requests for
Agenc records is established as follows'
(1 I For each one quarter hour, or fraction
thereof. spent In clerical personnel in
searching for a record. $1.50;
(2) For each one quarter himr. or fraction
thereof. spent b professiimal ixersiumel in
searching for a record. $3 50.
(3) For each on-line computer search,
$11.0(1;
(4) For each off-line (batch) computer
search of Central Reference files, $27.00)
(5) For all other off-line computer
searches of Agency files, $8.00 per minute
of Central Processing Unit (CPU) time;
(6) For copies of paper documents in sizes
not larger than 81/2 X 14 inches, 80.10 per
copy of each page:
(7) For duplication of non-paper media
(filni, magnetic tape. etc.) or any document
that cannot be reproduced on a standard
office copier. actual direct cost; and
(8) For extra copies of reports, maps,
reference aids, and other Agency publica-
tions. actual cost.
(d) Inasmuch as the Agency's systems of
records are highly decentralized, several
computer searches may be required to pro-
cess a request, depending upon its scope.
The computer search costs given in para-
graph to, of this section. do not include
whatever professional clerical search time
is needed to determine whether the records
located are in fact responsive to the request.
(eI Search fees are assessable even when
no records pertinent to the requests, or no
releasable records are found. provided the
requester has been advised of this fact and
he has. that notwithstanding agreed to in-
cur the costs of search
tf) For requests which have accrued sub-
stantial search and duplication fes, or for
requests for records which have been previ-
ously released. or where there is reasonable
evidence that the requester ma possibly
fail to pal the accrued fees, then, at the
discretion of the Coordinator, the requester
mas he required to pal the accrued search
and duplication fees prior to the actual
delixerN of the requested records: other-
wise. the requester shall be biffed for such
fees at the time that the records are provid-
ed. Payment shall be remitted b) check or
inone order, made payable to the Treasur-
er of the United States, and shall be sent to
thr Coordinator No appeals or additional
requests shall be accepted for processing
until the requester has paid all outstanding
charges for services rendered under this
part
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
?.-1:
? I.
JAMES H. LESAR,
)
)
Plaintiff,
)
)
v.
)
Civil Action No.
84-211,1
)
CENTRAL INTELLIGENCE AGENCY,
).
)
Defendant.
)
)
ORDER
This matter has come before the Court on plaintiff's applica-
tion for a temporary restraining order and counsel have been heard
in open court. It appears to the Court that plaintiff has delayed
unduly with regard to his request of June 28, 1983, and that the
defendant should have an opportunity to search for and process
records responsive to plaintiff's request dated August 24, 1984.
It is, therefore, this 17th day of September, 1984,
ORDERED that plaintiff's application for a temporary restrain-
ing order is denied; and it is further
ORDERED that when defendant files its answer, which is due
on October 17, 1984, it shall include a statement as to when the.
search for and processing of responsive, documents shall be
completed; and it is further
ORDERED that, if in the meantime particular documents are
located which can readily be released to plaintif44 the defendant
may do so in its discretion without prejudice to the schedule it
proposes when it files its answer.
United States District Judge
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II I FP.IR
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4 ?4M.4um.LQu alAudb in..511tIC1 0OU1T
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
SAINVIL
vs.
UNITED STATES DEPARTMENT CF STATE
and UNITED STATES OWERAL nymurENcy
AGEICY
BEFORE WEINER, J.
AND NCW, this
6th
day of
CIVIL ICTICN
NO. 84-0108
FILED.
RR 611K
tict,AEL cle
APRIL , 1984,
it is ORDERED that pursuant to agreement of counsel the above-
entitled matter is Dismissed without Prejudice. The case is to
remain in status quo and the Statute of Limitations is tolled.
It Is Further agreed that if the transaction of
this matter is not resolved between the parties, this action maybe
reinstaf:ed and placed an the acrive docket by any of the parties
ftrectly to the Court.
(!//1
/)-rt
4/9/84 copy mailed to:
L.Rieser,Esq.
A.Ewing.Jr.A.U.S.Atty
(L.E.)
OR BY THE COURT:
JI.DZ;?
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rai tea.
IP
? or
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ANTHONY SUMMERS, )
)
Plaintiff. )
)
v. ) Civil Action No. 84-2754
)
CENTRAL INTELLIGENCE AGENCY )
et al )
)
Defendants. )
)
STIPULATION
FILED
OV 834
JAMES F. DAVEY, Clerk
Pursuant to the discussion at the status call on October 24.
1984, the parties stipulate as follows, subject to the Court's
approval.
I. Plaintiff filed this action on September 10, 1984,
seeking records from the following agencies or components of the
United States government:
A. The Federal Bureau of Investigation (FBI)
B. The Central Intelligence Agency (CIA)
C. The Department of the State
D. The Department of the Treasury
E. The Department of Justice
1. The Criminal Division
2. The Office of the Attorney General
3. The Office of Intelligence
Policy and Review
Plaintiff seeks these documents to assist in research on a book
on the death of movie actress Marilyn Monroe.
II. The agencies and components have been processing
plaintiff's requests both before and after this case was filed.
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In addition, continuing and extensive discussions have taken
place between counsel for the parties and agency representatives
regarding the handling of plaintiff's requests.
III. This stipulation has .been entered in order to accom-
modate four concerns:
A. The creerly dispo..iition of this lawsuit.
B. Plaintiff's desire to receive materials
pertinent to his research within a
reasonable time.
C. The need to reduce the tasks presented to
the agencies in order to accomplish III
B above.
D. The need to process the records in a careful
manner, so that plaintiff will receive that which
he is entitled to, while at the same time assuring
that exempt information is properly protected,
classified mi,.terial, internal memoranda,
confidentiality and legitimate privacy interests.
IV. Because of the limited amount of its potentially
responsive material, the State Department has completed its
processing of the documents, and has reported the results to
plaintiff, furnishing certain documents. The Treasury Department
and the Justice Department component* other than the FBI have
completed their searc!-as and re7orted tc Flaintiff tha: they have
no responsive doc=ents.
V. Plaintiff and defendant FBI have agreed to a reformu-
lation of the scope of several of plaintiff's Freedom of Infor-
mation Act (FOIA) requests as specifically set forth below. This
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reformulation recognizes the desire on the part of the plaintiff
to receive as much information as soon as possible on the ultimate
subject of his various FOIA requests; that being the life and
death of Marilyn Monroe and her relationships with various public
figures, including Robert F. and John F. Kennedy. This reformula-
t a:!: thv E7.,:.unt of inforn.ation in
files relevant to the subject of the actual individual request
which appears to have no relevance to the research on plaintiff's
book. For example, in the Spindel request (Request 245455, Count
II) Federal Bureau of Investigation Headquarters (FBIHQ) files
contain approximately 6,000 pages relating to Spindel, but very
few references either to Marilyn Monroe or to the two areas
plaintiff deemed related. Therefore, the reformulation will
reduce the amount of processing yet to be addressed by the FBI
and hasten its completion.
In general, records on each reformulated request will first
be reviewed to determine if they bear in any reasonable mannef on
Monroe during the period 1961-1963 or late 1966 - early 1967.
The dates 1961-1963 have been chosen because they represent the
several years prior to and after her death. The late 1966 -
early 1967 period was chosen because of allegations that certain
wiretap tapes of Monroe's voice with others were confiscated in a
raid by local authbritie's on Spindel's home. Once these records
are rE".-iE:s.E::.
request will be processed under the FOIA for release to plEintiff.
It is understood that this stipulation controls the extent of the
FBI's FOlA processing of the subjects discussed herein and that
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those prior requests which have been reformulated are rendered
moot by this stipulation.
This stipulation will also address the amount of material
remaining to be processed under the reformulation and the approx-
imate amount of time necessary to accomplish this. In addition,
this stipulation will describe in general terms the material
requested by plaintiff which has already been processed and
released.
A. Marilyn Monroe: The FBI has already furnished
plaintiff with previously processed material concerning Monroe.
In addition, 25 "see" references (amounting to approximately 180
pages) must be processed for FOIA exemptions by the Disclosure
Unit of the FBI's Freedom of Information Privacy Acts (FOIPA)
section, Records Management Division (RMD). These "see" refer-
ences must also be processed by the Classification Appeals and
Affidavits Unit (CAAU) of the FBI's RMD to determine if classi-
fied information is contained in the "see" references. The FBI
represents that: (1) The task of processing these documents to
afford maximum releasability to plaintiff while insuring that
applicable provisions of Executive Order 12356 (regarding National
Security Information) are complied with is a time consuming one
and accounts for a majority of the processing period. (2) In
fprocessing "see" references, it is necessary to examine not only
the references themselves. but also other documents bearing on
releasability, which may be extensive. (3) This review by the
Classification Appeals and Affidavits Unit is also necessary for
other porticns of plaintiff's requests and this discussion simi-
larly applies to those requests and will be noted as appropriate.
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B. Novotny: Preprocessed material concerning Novotny
had already been made available for release to plaintiff while 18
additional "see" references remained for processing. It has
recently been determined that these "see" references are identi-
cal to material already provided plaintiff through the "Bowtie"
request (discussed infra). Therefore, no further processing
remains on Novotny.
C. Greenson: Eight "see" references amounting to
approximately 20 pages must be processed by the CAAU and then
returned to the Disclosure Unit for further processing and
release to plaintiff.
D. Sukarno: One 160 page "main" file and 132 "see"
references pertaining to Sukarno were reviewed according to the
reformulated request and 40 "see" references amounting to approx-
imately 100-130 pages were determined to be relevant and must be
reviewed by CAAU and then returned to the Disclosure Unit for
further processing and release to plaintiff. 1/
E. Field: 850 pages pertaining to Field must be
reviewed by CAAU prior to review by the Disclosure Unit before
release. Plaintiff has indicated that processing of the Field
material is not a priority matter and therefore it is agreed that
while this material will be processed, it will be done only after
other priority prc!,cessing has been comTleted. This wi41 not be
accomplished within the deadline covert? this stipulation.
1/ in the case o: Sukarno, the request was reformulated to
relate to Sukarno's sexual proclivities.
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F. 94-37374: This file is identical to Hoover's "OEC"
files on John F. Kennedy and has been preprocessed for release to
other requestors. Arrangements are underway to forward this
material to plaintiff.
G. Miller, Frasca, Chang, Renay: Plaintiff has been
advised that without written authorization from these individuals,
the FBI could neither confirm nor deny the existence of records
pertaining to them because to do so would constitute an imper-
missible invasion of their personal privacy. Plaintiff has to
date not provided these authorizations and therefore the FBI has
not searched its central records systems indices for references
to them. No action is, therefore, to be taken as to them.
G. Bowtie: Certain preprocessed material on "Bowtie"
requested by plaintiff has been forwarded to him.
H. Horan: Eight "see" references amounting to approx-
imately 20 pages must be reviewed and processed by the Disclosure
Unit, and, if classification implications are found, these
references must also be reviewed by the CAAU.
I. Capell: The Disclosure Unit has reviewed approxi-
mately 1,600 pages of material pertaining to Capell with the
objective of determining its relevance to the reformulated
request. Material dated from 1961-1963 was reviewed for any
connection to Marilyn Monroe, Robert F. Kennedy and/or either or
both of their seual proclivities or Monroe's suicide and none
2/ Plaintiff reserves the right to request that the "Bowtie"
material be re-classified but it is agreed that such reclassifica-
tion will not be accomplished in the time period specified
herein.
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were located. Therefore, no further processing of these files
3/
will be undertaken. ?
Spindel: In an effort to reduce the amount of proces-
sing inecessary on the approximately 6,000 pages pertaining to
Spindel, it was agreed that the various FBIHQ files would be
grouped in beginning and ending date order and that only those
files or references falling within the relevant dates would be
reviewed for relevance to the reformulated request. It was agreed
that files which fell within 1961-1963 and all of 1967 would be
reviewed. For example, if a file was opened on January 2, 1960
and closed on January 1, 1962 it would be reviewed; conversely,
if a file was opened on October 1, 1955 and closed on October 1,
1960, it would not be reviewed. Only those files which were open
at some period within the relevant dates were reviewed. Based on
these parameters, Special Agent Douglas S. Garrison of the FBI's
Legal Counsel Division personally reviewed approximately 20 main
files or "see" reference for information falling within the reformu-
lated request. In addition to the general reformulation discussed
earlier, this material was also reviewed to determine if it contained
references to a raid by local authorities on Spindel's home in
which tape recordings pertaining to Monroe were seized, or any
lawsuit relating to said raid. Five references were located which
are arguably within the scope of the reformulated request, one of
which is a public source document. These documents will be
3/ During the parties disc-,:ssich of this stipulation, plaintiff
requested an amplification of the reformulation as to Capell.
The parties intend to present a supplemental stipulation in this
respect on or before November 30, 1984.
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revicw(..d by the Disclosure Unit for processing,-and, if necessary
by the CAAU, prior to release.
On February 16, 1964 after a request from plaintiff for
records on Spindel, the New York Office of the FBI advised plain-
tiff that a search of the New York Office indices had not located
any references to Spindel. After a review of Ibli!Q files by SA
Garrison, a number of communications from New York were noted,
indicating that New York had records which they had failed to
locate. Upon re-examination of the New York Office indices,
records pertaining to Spindel were located and are currently
being processed for release in accordance with the reformulation
described herein. This processing will be completed within the
time established by this stipulation.
J. Balletti, Ratterman: The FBI identified the Balletti
materials and plaintiff's counsel informed the agency that he had
received them for a different requestor. It was agreed that they
wc,..ld not be further processed. SA Gartison informed plaintiff's
counsel that the Ratterman materials did not contain any reference
to Marilyn Monroe or to her involvement with Robert F. Kennedy or
John F. Kennedy. Plaintiff has requested that the public source
material relating to Ratterman be processed. The FBI will do
this, and will ascertain whether this can be accomplished within
the time period specified herein.
VI. The FE1 re.7'resent5 that it hzs comr4_:teC considerable
personnel and resources tu the processing agreed upon in this
stipulation, consistent with its huge backlog of FOIA requests in
processing and litigation, many of which are under court deadlines.
It is agreed that the FBI will complete the processing of plaintiff's
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reformulated request within three months of the date of this
stipulation. It is agreed that as material is processed, it will
immediately be forwarded to plaintiff on a continuing basis.
Plaintiif has indicated that he desires that processing of
the Monroe "see" references be accomplished first, followed, in
order of pricrity, by Suki.rno, Greenson and Horan.
VII. The CIA.
A. On 3 August 1983 plaintiff submitted a FOIA request
to CIA for information pertaining to the following' 12 persons:
Arthur Miller
Joe DiMaggio, Sr.
A. Frank Cappell
Judith Meredith
Fred Otash
Reed Wilson
Fred Bauersfeld
Frank Sinatra
Stanley Gerbobaz
Hyman Engleberg
Arthur James Balletti
Ralph Greenson
B. On 25 August 1983 defendant CIA responded to the
plaintiff's FOIA request of 3 August by requesting biographic data
on the following six persons:
Judith Meredith
Fred Bauersfeld
Fred Otash
Stanley Gerbobaz
Reed Wilson
Arthur James Balletti
C. Also in CIA's response of 25 August it requested
statements au:horizine the release of personal information on the
following 10 persons:
Arthur Miller
Joe DiMaggio, Sr.
Judith Meredith
Fred Otash
Reed Wilson
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Fred Bauersfeld
Frank Sinatra
Hyman Engleberg
Ralph Greenson
Arthur James Balletti
D. Further, in its letter of 25 August defendant CIA`
denied a fee waiver which had been requested by plaintiff in his
letter of 3 August.
E. On 22 December 1983 plaintiff provided copies of
death certificates pertaining to Frank A. Capel]. and Ralph R.
Greenson.
F. On 11 January 1964 defendant CIA acknowledged
receipt of the two aforementioned death certificates and reminded
plaintiff that he had not made a commitment to pay search fees.
Plaintiff was told that further processing of his request would
be held in abeyance pending his comritment to pay search fees.
G. On 28 November 1963 plaintiff made a FOIA request
to CIA for information pertaining to Fredrick Vanderbilt Field.
Plaintiff enclosed a notarized privacy waiver from Mr. Field but
did not make a fee commitment.
H. On 14 December 1983 defendant CIA acknowledged
receipt of plaintiff's request pertaining to Field, and informed
plaintiff that CIA would not begin processing this request until
he had made a commitment to pay fees.
I. On 27 January 1984 plaintiff submitted a FOIA
request to CIA for records pertaining to Bernard B. Spindel.
Plaintiff enclosed a copy of Mr. Spindel's death certificate.
J. On 24 February 1984, CIA acknowledged receipt of
plaintiff's request pertaining to Mr. Spindel. CIA also asked
for Spindel's date of birth, and informed plaintiff that there
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could be no waiver of search fees at that time and that processing
of the Spindel request would be held in abeyance pending receipt
of plaintiff's fee commitment and Mr. Spindel's date of birth.
K. On 19 April 1984 plaintiff submitted a FOIA
request to CIA for records pertaining to Marie Novotny. A copy
of Ms. Novotny's death certificate was enclosed with this
correspondence. Plaintiff made no fee commitment in this request.
L. On 8 May 1984 defendant CIA acknowledged receipt
of plaintiff's FOIA request of 19 April
N. On 10 September 1984 plaintiff filed the instant
civil action.
N. On 24 September 1964 plaintiff made the requisite
fee commitments with respect to his requests for records pertaining
to Spindel and Capell.
O. The Central Intelligence Agency has undertaken a
thorough and diligent search of all appropriate records systems
for records pertaining to Messers Capell and Spindel.
P. With respect to Mr. Capell no records were found.
With respect to Mr. Spindel, CIA identified the
Q.
following records which may be responsive to plaintiff's request:
(1) 17 CIA documents consisting of approxi-
mately 45 pages; and
(2) 15 FBI documents consisting of approx-
imately 98 pages. (These documents arebeiig .
referred to the FBI for direct
response to the plaintiff.) 4/
4/ Until the FBI has hadan opportunity to review these referred
Uocuments, it cannot estimate the time for their processing.
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R. The responsive CIA documents pertaining to Mr.
Spindel contain only a single, two-sentence, reference to Marilyn
Monroe contained in a six page CIA document dated 20 February 1967.
VIII.
Pursuant
to the direction of this Court,
for plaintiff and CIA have met
plaintiff narrowing his
attorneys
and discussed the possibility of
request. As a result of those discussions,
plaintiff has agreed to narrow his request to include records
pertaining to Mr. Spindel which mention or reflect a relationship
or connection, of any kind, between Mr. Spindel and Marilyn
Monroe.
IX. Defendant CIA has agreed in turn to provide within two
days a copy of the document pertaining to Mr. Spindel which
contains the single reference to Ms. Monroe. (CIA has no other
documents responsive to the request as narrowed.) Although this
document will be sanitized,
released in its entirety.
X. Without further search fee
will continue to hold plaintiff's
abeyance./
the reference to Ms. Monroe will be
commitments, defendant CIA
remaining FOIA requests in
5/ On November 6, 1984, plaintiff's counsel orally stated to
Uefendants' counsel that plaintiff's counsel is writing a letter
making a fee commitment as to four additional individuals. The
parties are discussing the formulation of those requests and the
timing of their processing, and intend to supplement this stipula-
tion with an additional stipulation on or before November 30,
1984. With these four individuals, plaintiff concluded the
commitments which he is willing to make for searches on the
subjects which are within the scope of this lawsuit.
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XI. This action is hereby dismissed with prejudice as to
all agencies and components except the FBI, except that, if
documents are referred to any of the dismissed agencies and
components, plaintiff does not waive his right to litigate as to
the referred documents, and plaintiff reserves the right to
litigate the fee waiver issue. In the event plaintiff should
prevail on the fee waiver issue, he would not be foreclosed from
litigating the issue of CIA's position of requiring a death
certificate or authorization, where the request concerns living
persons, before searching. See also footnote 5 above. In order
not to interfere with the FBI's processing of documents, such
litigation shall not take place before February 6, 1985.
XII. Each party shall bear its own costs and attorneys'
fees, except as follows: in the event that plaintiff should
choose to challenge exemptions invoked by the government, and
should do so successfully, plaintiff reserves the right to seek
attorneys' fees and costs solely for such challenge, and
defendants reserve the right to oppose such application;
plaintiff also reserves the right to seek attorneys' fees and
costs if he successfully challenges denial of a fee waiver, and
defendants reserve the right to oppose such application.
XIII. This action is dismissed without prejudice as to the
FBI. Plaintiff rtserves the right to move to reinstitute this
action as to the FEI--which motion tL.- FBI shall not oppose- on
or after February 6, 1985. The reformulations of requests
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specified in this stipulation shall fully govern in any such
reinstituted lawsuit.
231 Fourth Street, S.W.
Washington, D.C. 20024
276-0404/646-0903
Attorney for Plaintiff
Approved this
Respectfully submitted,
A-2(c64 g. .4chre.1.4.4 ffe%
JOSEPA E. DIGENOVA
United States Attorney
r.
ROYCE C. LAXIERTH
Assistant United States Attorney
g/A, pbodfd
6'
NATHAN DODELL
Assistant United States Attorney
U.S. Courthouse - Room 2814
3rd E. Constitution Avenue, N.W.
Washington, D.C. 20001
(202) 633-4978
etioto
Attorneys for Defendants
day of November, 1984 -
tf- A -e-
UNITED STATES DIST
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